Legal Opinion

Estate of Wall v. Commissioner

United States Tax Court

Decided March 7, 1994No. Docket No. 15311-91Published

P filed a motion pursuant to Rule 231, Tax Court Rules of Practice and Procedure and sec. 7430, I.R.C., seeking reasonable administrative and litigation costs, claiming that R's position was not substantially justified. Held, R's position was substantially justified for purposes of sec. 7430, I.R.C.

1Opinion of the Court

Estate of Helen S. Wall, Deceased, Kathryn H. Barth, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent *

Estate of Wall v. Commissioner

Docket No. 15311-91

United States Tax Court

102 T.C. 391; 1994 U.S. Tax Ct. LEXIS 15; 102 T.C. No. 13;

March 7, 1994, Filed

An appropriate order and decision will be entered.

P filed a motion pursuant to Rule 231, Tax Court Rules of Practice and Procedure and sec. 7430, I.R.C., seeking reasonable administrative and litigation costs, claiming that R's position was not substantially justified. Held, R's position was substantially…

2Cases cited6 opinions

  1. Pierce v. UnderwoodSupreme Court of the United States · 1988
  2. Stephen P. Wilfong v. United StatesCourt of Appeals for the Seventh Circuit · 1993
  3. Archbold Van Beuren v. Martin M. McLoughlin (Former Acting Collector of Internal Revenue), DefendnatsCourt of Appeals for the First Circuit · 1959
  4. Corning v. CommissionerUnited States Tax Court · 1955
  5. Estate of Wall v. CommissionerUnited States Tax Court · 1994

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